Centralized exchange in Mali

December 2021: The BCEAO issued a directive (Circular N°0000000001/M/DG/2021) explicitly prohibiting financial institutions under its purview from engaging in any activities related to virtual assets.

April 2022: The BCEAO Governor, Tiémoko Meyliet Koné, reiterated this prohibition, warning against the risks associated with cryptocurrencies.

July 2023: Another communication from the BCEAO confirmed its continued vigilance and prohibition.

They are not recognized as legal tender within the UEMOA zone.

They are not regulated or supervised by the BCEAO or any national financial authority in the region.

Financial institutions supervised by the BCEAO (banks, microfinance institutions) are generally prohibited or strongly discouraged from engaging in activities related to virtual assets due to the associated risks (money laundering, terrorist financing, consumer protection, financial stability).

None specifically for crypto. Since there is no dedicated crypto regulatory framework, there are no specific licenses for these activities.

Neither a registration nor a specific licensing regime currently exists for VASPs in Mali.

Entities operating in this space are doing so outside of a recognized regulatory framework. This is not a "light touch" approach; rather, it indicates a lack of formal permission or supervision, which can be interpreted as implicitly disallowed for formal financial sector participation.

Evidence fact ml.custody.no-specific-custodial-license-requirements-for not found (may have been renamed).

No specific rules exist for the segregation of client assets for cryptocurrency custodians. This is due to the absence of a dedicated regulatory framework for crypto custody.

No specific cold storage mandates or any other operational security requirements are legally defined for cryptocurrency custody in Mali.

Law N°2018-024 of August 21, 2018, amending Ordinance N°2015-032/P-RM of June 19, 2015, relating to the fight against money laundering and terrorist financing.

Customer Identification and Verification:

Beneficial Ownership Identification: Identifying and verifying the natural persons who ultimately own or control the customer, or the natural person on whose behalf a transaction is being conducted.

Purpose and Nature of Business Relationship: Understanding the purpose and intended nature of the business relationship or occasional transaction.

Ongoing Monitoring: Conducting ongoing due diligence on the business relationship and scrutinizing transactions undertaken throughout the course of that relationship to ensure consistency with the institution’s knowledge of the customer, their business, and risk profile.

Risk-Based Approach: Applying enhanced due diligence (EDD) for higher-risk customers (e.g., politically exposed persons - PEPs, customers from high-risk jurisdictions, or those engaged in complex/unusual transactions) and simplified due diligence (SDD) for lower-risk scenarios.

Obligation: Any transaction (regardless of amount) that an institution knows, suspects, or has reasonable grounds to suspect is related to money laundering or terrorist financing must be reported.

No Tipping-Off: VASPs and their employees are prohibited from disclosing to the customer or third parties that an STR has been filed or that a money laundering or terrorist financing investigation is being conducted.

Transaction Records: All transaction data, including the amount, currency, date, and details of the parties involved (originator and beneficiary), should be kept.

Cellule Nationale de Traitement des Informations Financières (CENTIF): Mali's FIU, responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs).

Outcome: A de facto ban on formal cryptocurrency operations within Mali's regulated financial sector. Financial institutions are prohibited from offering crypto services, and the public is warned about the risks and lack of regulatory protection.

Outcome: Arrests, investigations, and potential prosecutions of individuals involved in scams. Public awareness campaigns to warn citizens against unregulated crypto investment opportunities.